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Abstract
In the current debate on international accounting harmonisation, references are made to accounting model categories. In particular, a distinction is made between the Anglo-American accounting cluster and the continental European cluster. First, we provide a review of the related accounting classication literature. Dierent classication results
can be traced back to dierences in the conceptional and methodological research designs. Second, my own classication attempt is presented which is founded on an actual database of nancial reporting requirements in 14 countries
and the IASC. Basically, a picture of an Anglo-American or continental European accounting model cannot be
established. # 2001 Elsevier Science Ltd. All rights reserved.
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328
harmonisation could be either supported or questioned by explicit attempts that prove or deny the
existence of the postulated national accounting
clusters. Furthermore, it would be easier to discern
the advantages gained from classifying accounting
systems into models if systems in one cluster had
relatively similar characteristics. To illustrate,
accountants can specialise in national accounting
systems of a specic accounting cluster (Berry,
1987, p. 90), national standard setters may anticipate accounting problems and solutions by looking at the experience of other countries from the
same cluster (Meek & Saudagaran, 1990, p. 154),
or policy-makers may better assess the prospects
and problems of international harmonisation
(Radebough & Gray, 1993, p. 61).
Roberts (1995, p. 641) shows that classications
are neither right nor wrong but useful or less useful for specic research questions. However, the
question remains whether the view of a dichotomised accounting world, implied by certain
authors, is appropriate according to the international harmonisation debate.
When analysing the related literature it is
apparent that explicit classication attempts suggest contradictory groupings. We note that the
dierentiation between Anglo-American and continental European accounting is not statistically
proved. For example, in some classications, the
US and Great Britain are in dierent groups (Da
Costa, Bourgeois & Lawson, 1978; Doupnik,
1987; Frank, 1979; Goodrich, 1982; Nair &
Frank, 1980; Shoenthal, 1989). Furthermore,
Alexander and Archer (2000) seek to establish that
``Anglo-Saxon accounting'' is a myth by critically
examining four putative commonalties which are
frequently attributed to the UK and USA
approaches to nancial accounting.
As a result, the use of these classications in the
international harmonisation debate may be questioned. This paper analyses whether there is a
contradiction between the intended use and the
scientic ndings and shows possible consequences for the political process of accounting
harmonisation. Basically, the question of whether,
and under which conditions, an Anglo-American
and a continental European accounting group can
be identied needs to be resolved. Moreover, this
329
330
accounting aim to validate the assumed dependencies (Cooke & Wallace, 1990; Nair, 1982; Nair
& Frank, 1980). To reduce complexity, some of
the approaches investigate the relationship with
respect to a specic accounting problem (Needles,
Powers & Revsine, 1991) or a single factor
(Doupnik & Salter, 1995; Shoenthal, 1989), or
focus on a narrow selection of national environments (Cooke, 1992; Hagigi & Sponza, 1990).
The most sophisticated and most frequently
cited approach in this research area is that of
Nobes (1983, 1992). His empirical results prove
the predicted relationship. But the core assumptions on the direction and intensity of the inuence, i.e. the subjectively determined scores, are
derived from the hypothesis to be tested (Doupnik
& Salter, 1993, p. 44). Despite this potential
objection, the research design has been copied and
referred to ever since (AlNajjar, 1986; Doupnik &
Salter, 1993, 1995).
Although most authors agree with the environmental view, there are several, partly contradictory groupings. Coming back to the original
question, whether an Anglo-American or continental European accounting cluster can be identied, the existing cluster attempts do not provide
us with a straightforward answer. In contrast to
the expectation, the ndings of most investigations
suggest separate UK and US groups (AAA, 1977;
Frank, 1979; Mueller, 1968; Nair & Frank, 1980;
Seidler, 1967; Shoenthal, 1989). A more dierentiated view provides Nobes (1992) and Doupnik
and Salter (1993, 1995) with a hierarchical solution. It is only in the two-cluster-solution that the
UK and US are both grouped in one cluster.
The problem arises because the choice of relevant elements, which should separate environmental areas, is as subjective as the methods of
measurement and the explicit relation to accounting systems. The list of important environmental
factors proposed by the descriptive approaches
are seldom used by the empirical researchers.
Mathews and Perera (1991, p. 305) conduct an
analysis of factor selection in six prominent papers
and show that they are far from any general
agreement about the main environmental factors.
Additionally, one has to take into account that
there are not only national environments but
331
nationally.1 All these attempts show serious differences in accounting practices. The rst
approaches using statistical methods to cluster
national accounting systems according to reporting practices are found in the late seventies (Barrett, 1977).2 The publication of three databases on
accounting practices by Price Waterhouse (1973,
1975, 1979) was the driving motive for several
researchers to use factor analysis to nd national
accounting clusters. In 1978 Da Costa et al. tested
the posited existence of groupings of accounting
models using this database. They were followed by
Doupnik (1987), Frank (1979), Goodrich (1982),
Nair (1982), Nair and Frank (1980) and Nobes
and Matatko (1980). In the nineties, other
empirical studies with partly new databases test
the relationship between accounting practices
classication and certain environmental inuences
(Nobes 1992; Salter & Doupnik, 1992; Doupnik &
Salter, 1993, 1995).
The results are as non-homogeneous as at other
levels already mentioned. However, for all the
investigations which use the Price Waterhouse
surveys as a database, two dierent clusters for
UK and US can be distinguished.
In addition to the problem that there is no consensus as regards national accounting clusters,
several limitations characterise the attempts on
this level. In the last section, we saw that dierences do not occur only in an international but
also in an intranational context (Archer et al.,
1995, p. 67). Furthermore, temporal events can
inuence the cluster result. Unsystematic inuences such as cyclical uctuations or management
incentives may adulterate the ndings. Nobes
1
First, some approaches examine the actual impact of differences in income or equity by comparing the national numbers from various enterprises with the amounts after a
reconciliation to US-GAAP (Amir, Harris & Venuti, 1993;
Weetman & Gray, 1991). Others try to measure the dierences
by indexes as an indicator for harmonisation eorts (Archer,
Delvaille & McLeary, 1995; Emenyonu & Gray, 1992; Herrmann & Thomas, 1995) or other approaches (Joos & Lang,
1994; Walton, 1992).
2
It is possible to see a plain bipartition in intuitive and
statistical methods of analysis: until 1977, ending with the
AAA, only intuitive methods can be found, since 1977, starting
with Barrett, statistical techniques are applied.
332
(1983, p. 5) is critical of the hypotheses. The clustering of the Price Waterhouse data should be
used to ``generate theories'', not to prove them
(Nobes & Matatko, 1980, p. 11). Several practical
problems also exist, e.g. answers are needed for
the following questions: what do accounting practices entail and how can these practices be carried
out? All the databases are founded on the analysis
of several annual reports. Consequently, the
results are biased towards the specic enterprises
chosen for data collection (Nobes, 1983, p. 3).
Further critiques of attempts using accounting
practices for cluster purposes concentrate on the
Price Waterhouse surveys. In order to create an
adequate database on this level for classication
purposes, the results of the attempts should be
interpreted with caution. However, one advantage
of classications using accounting practices is that
they provide us with new insights into international accounting dierences and thus consequently serve as a useful source of information for
the harmonisation debate.
1.5. Clustering nancial reporting requirements
It is astonishing that no one has attempted to
classify national accounting systems by nancial
reporting requirements. Of course, there are several investigations which collect or analyse the
dierences in accounting standards in several
countries (Gray et al., 1984; Ze, 1972). Yet none
of them build clusters based on their ndings. One
reason could be that a database, such as the one
provided for accounting practices by the three
surveys of Price Waterhouse, does not exist. Rahman et al. (1996) analyse the congruency of nancial reporting requirements in order to learn
something about ``formal harmonisation'', but
only for the accounting systems of Australia and
New Zealand (Rahman et al., p. 338).
The term ``nancial reporting rules'' has to be
dened rst. As we know from the classication
approaches based on standard setting processes,
dierent processes generally imply dierent types
of accounting rules. Nevertheless, the functions of
these dierent types of rules are similar, namely
the control of the accountant's behaviour. A system of accounting rules explicitly or implicitly
process). The actors' preferences are in turn aected by actors' incentive structures which are inuenced by various environmental factors (Bockem
& d'Arcy, p. 71). Consequently, national accounting rules reect environmental factors in the
specic outcome of the actors' incentives and preferences and allow the accounting systems to be
interpreted as human activity systems.
As with the other approaches, we are aware of
the limitations. Firstly, the choice of the variables
used to separate clusters is still subjective. Dierent choices would result in dierent cluster solutions. Secondly, the intensity and eectiveness of
nancial reporting in a country is a function not
only of the reporting requirements but also of the
degree of enforcement. Consequently, it is possible
that an accounting method is required but not
used, or that it is forbidden but possible to nd in
some nancial statements. Or a method may be
allowed but it may be used often or hardly at all.
Moreover, accounting practices require judgement
and there may be dierences in practices between
national accounting systems. Additionally, there
may be dierent rules for enterprises within a
country and/or the same rules for enterprises in
various jurisdictions. However, we are able to
resolve the latter problem if we concentrate purely
on the rules for listed companies. But we must be
aware that we only compare national accounting
rules for listed companies and not rules regarding
all types of companies. This can be justied by the
core arguments of the harmonisation debate that
concentrate on rules for listed companies. However, even if the use of international rules for listed
companies are accepted another debate may
explicitly state the negative impact of this on
nancial reporting rules for non-listed companies,
especially for tax purposes. Finally, it is also possible to argue that de facto harmonisation is more
relevant than the de jure harmonisation that is
followed in this paper. The harmonisation eects
of IASs and international capital market consideration typically make themselves apparent
through changes in practices before changes in
national requirements. But still a de jure harmonisation is necessary to force a de facto harmonisation for all companies not only on a voluntary
basis.
333
334
p. 2). Furthermore, the database mixes up information on accounting rules and practices, because
categories that include both types of information
such as ``rarely or not found'' and ``not permitted''
are used. This results in dierent aggregation
levels. Finally, the information is outdated, for
example the changes relating to the 4th, and 7th
EU-Directives are not included.
Some of the aforementioned problems also arise
with the other used databases. In particular, the
choice of variables used by AlNajjar (1986), Hofstede (1980) or Nobes (1992) are also subjective
and aected by their socio-economic environment.
Consequently, a self-generated database does not
immunise against these inuences. Furthermore,
subjective scoring systems are not suitable to test a
hypothesis because the same assumptions as for
the hypothesis are used. Additionally, Nobes and
AlNajjar use criteria on dierent aggregation
levels, namely causal factors and measurement
practices.
Except for the work of Doupnik and Salter, all
other statistical classication approaches use
databases that are ordinally scaled. Hence, the
data must be transformed because most statistical
methods allow the input of nominal or metric
(cardinal) data, only. Accordingly, some authors
convert the ordinal data into metric or use the
ordinal categories as metric numbers directly. This
renders statistical analysis such as the calculation
of averages possible, although the data foundation
is not suitable for this purpose.
It is notable that the criticism of certain classication attempts concentrates on the scope of analysis and the databases but never on the statistical
procedures.4 This is astonishing because consensus
in the statistical methods to be used cannot be
found at all. A relatively sophisticated and wellknown procedure to nd accounting clusters is
factor analysis. Basically the clusters are built
based on the highest rotated factor scores (Eigenvalue>1) so that there are as many clusters as
factors. Each item (country) is attributed to a
4
Even though Nobes (1983, p. 5) criticises the application of
factor analysis because this method does not produce hierarchies, he does not discuss the main problems which result
when clusters are found.
335
Table 1
Content of the current database
P
Topics
Example
Individual accounts
Recognition assets
Recognition liabilities
Valuation assets
Valuation liabilities
Revaluation accounting
Group accounts
Full consolidation set
Proportional consolidation set
Uniformity of accounts
Foreign currency translation
Consolidation of capital
Consolidation of debt/prots
Equity method
Deferred taxation
5
Details about how this data are derived are available on
request from the author and are reported in d'Arcy (1999).
6
The symbols represents the following (Ordelheide & Semler, 1995, p. 4):
336
than 50% and up to 70% congruence. Consequently, most pairs are neither extremely homogeneous nor heterogeneous.
Concentrating on high distances besides France
and the US, the results derived from the Australian system are remarkable. Only the IASC
shows a coecient close to the average. All other
pairs including Australia are measured with less
than 60% congruence. Correspondingly, the Australian system seems to have an outsider position.
Moreover, the ndings imply that statements,
which refer to the comparability of two systems,
should only be interpreted with caution. For
example, an isolated analysis of Canada and the
US shows that both systems with 67.44% congruence reach the highest value for each other,
meaning that for Canada the US system is the
most comparable and vice versa. But taking all
national systems into account, there are 15 pairs
that lie in an interval of higher congruence.
3.2. Cluster solutions
As the rst method the Average Linkage
between Groups is chosen because it combines
certain characteristics of the Single and the Complete Linkage. Fig. 1 shows the dendrogram for
the Average Linkage solution.
This dendrogram illustrates the fusion process
and should be read from the top left to the bottom
right. The numbers are the standardised similarity
coecients (fusion distances) that are relevant for
each fusion.7 The rst cluster is Germany and
Austria as expected. Belgium and France follow it.
These four national systems form a clear cluster,
which could be characterised as a continental
European group. This group is enhanced by other
European systems such as Switzerland, Denmark,
the Netherlands and the UK, so that a European
group emerges. A second, more heterogeneous
group with Spain, Japan, and Sweden merges with
the rst group. Canada, US and the IASC form a
third group, approximately at the fusion level of
7
The applied Software SPSS standardizes the fusion distances from 1 to 25. The rst fusion, in the present contribution
Germany and Austria, gets the fusion distance 1, the last fusion
the fusion distance 25 (Norus is, 1994, p. 91).
Table 2
Survey of some characteristics of the main classication attempts
Study
Findings
P
Countries
Classication criterion
Database
Method of analysis
Cluster
Hateld (1911)
USA
Financial reporting
practices
Self-generated
Intuitive
Seidler (1967)
USA
Spheres on inuence
based on economic,
political and legal
factor
Self-generated
Intuitive
None
British, US,
continental-European
Mueller (1967)
Importance of economic,
Self-generated
Intuitive
None,
Patterns of development:
USA
accounting development as a
framework for analysis
governmental, business
factors in the development
of accounting systems
Mueller (1968)
USA
States of economic
development, of business
complexity, shades of
political persuasion,
examples
for each
group
Self-generated
Intuitive
None,
exampIes
for each
group
macro-economic (SWE),
microeconomic (NETI-I),
independent discipline
(UK, US), uniform (GER)
10
Sets of business
environments, e.g.
US/CAN/NETH, British
Commonwealth (without
reliance on some
particular system of law
CAN), GER/JAP
Previts (1975)
USA
Self-generated
Intuitive
AAA (1977)
Self-generated
Global
Intuitive
USA
inuencing factors
Barrett (1977)
USA
Disclosure practices
(17 items of
information drawn
from annual reports of
103 rms 19631972)
Self-generated
Uniform
Ordinal
! cardinal
Da Costa et al.
(1978) Canada
Accounting practices
(100 out of 233)
PW 73
Various
Ordinal ! ? Principal
(not specied, component
None
2
(as
hypothesis)
Anglo-American,
Continental
6 as
British, FRA/ES/POR,
example
probable
cardinal)
Weighted index
GER/NETH, communistic
US/UK, JAP/SWE/NETH/
GER, FRA
(others not classied)
38
Study topic
factor analysis
+ Q-analysis
based on sum
scores on each
factor, for each
country
337
338
Table 2 (continued)
Study
Frank (1979)
USA
Findings
Study topic
Classication criterion
Database
Method of analysis
Accounting practices
(233)
PW 73 +
self-generated
Various
Principal component
factor analysis,
grouping based on
highest rotated
Ordinal
! cardinal
(% of usage)
Countries
38
Examine dierences in
classications whether
measurement or disclosure
practices are used + the
association with underlying
Accounting practices
dierentiated in
measurement
(mp=147/162)
+disclosure
environmental variables
practices
(dp=86/102)/
environmental
factors
PW 73+75+
self-generated
Various
Ordinal
! cardinal
(% of usage)
Principal
component
factor analysis,
grouping based
on highest rotated
PW 73+75
Various
Nair (1982)
Accounting
PW 79
Various
USA
practices
dierentiated in
measurement
practices (mp) and
disclosure
practices (dp) (267)
38/46
Goodrich (1982)
Accounting
UK
principles
and policies (26)
Doupnik (1987)
USA
Accounting
practices
(70)
PW 79
PW 75 +
self-generated
Uniform
Various
Factor analysis
(following DBL) +
Q-Analysis
38
64
Ordinal
Principal component
factor analysis,
grouping based on
highest rotated
factor scores
Ordinal
Factor analysis,
(Kendall
correlation
coecient)
grouping based on
highest (oblique)
rotated factor scores
Ordinal
! cardinal
(scores)
Factor analysis
(oblique rotation)
(after Nair/Frank)
British-Commonwealth,
Latin American, Continental
European, US-model,
indirect support of
4/5 (mp),
7/7 (dp)
Ordinal
! cardinal
! cardinal
(% of usage)
environmental determinism
theory
factor scores +
multiple discriminant
analyses
Accounting
practices
(233)
64
12
7 (mp),
Mp: British-Commonwealth,
10 (dp)
36
Cluster
factor scores
Puxty et al.
(1987)
Accounting
standard
setting
Self-generated
Intuitive
None,
examples
for each
group
Accounting
standard
setting
Self-generated
Intuitive
institutions in the
development and
enforcement of accounting
Nobes (1992)
UK
AlNajjar (1986)
USA
group
Two explanatory
variables +
seven measurement
generated morphology
and PW-data
practices,
accounting
practices (267)
Find classication of
standard setting processes
Accounting
standard
and institutions
setting
Five causal
factors, 11
standardisation
elements
Self-generated
Various
Ordinal !
cardinal
(scores 15)
Cultural value
dimensions
Hofstede 80
Uniform
Cardinal
(scores)
Self-generated + Various
PW 79
Ordinal
! cardinal
(scores 14)
Cluster analysis by
nearest neighbours
and furthest
14, 64
Various
because
hierarchical
Support hypotheses
(but few deviations)
Various
because
2-cluster solution:
non-government creation
hierarchical
Clustering by nearest + 8
farthest neighbour on
total dierences
between countries
Various
because
hierarchical
Support hypotheses
(but few deviations)
50
neighbours based
on roots of the
squared dierences,
dierent methods for
PW-data
Self-generated
Intuitive
Shoenthal (1989)
USA
1980)
Accounting
competencies
(63)
Self-generated
Uniform
Ordinal
Discriminant analysis
(dichotomised)
+ cardinal
339
Nobes
(19831994)
UK
None,
examples
for each
340
Table 2 (continued)
Study
Findings
Database
Disclosure
regulation
PW 79,
Uniform
Gray/Campbell/
Ordinal !
cardinal
Shaw 84
(scores)
reaction
Modied PW 79 Various
+ self-generated
Cardinal
Cluster analysis
(centroid + ward)
disclosure regulation in
developed countries is
likely to be determined
by more internal factors,
whereas that of
developing countries by
Method of analysis
21
Countries
Cluster
4/3, highly
regulated
Support hypotheses,
UK/US ``leader'' in
to under
regulated
nancial disclosure
regulation
Various
because
hierarchical
Support hypothesis,
substantial
dierences in
accounting systems
can be
explained by
Accounting
practices
(100)
50
reference to a
country's laws
(code versus case
law)
Doupnik and Salter Empirically classify current
(1993) USA
nancial reporting systems +
test the validity of a
classication proposed by
Accounting
practices
(100)
Modied PW 79 Various
+ self-generated
Cardinal
Cluster analysis
(average linkage
+ ward)
50
Various
because
hierarchical
Conrm Nobes's
classication (few
deviations), support
existence of a Latin
American group
suggested by Berry
Accounting
practices
(100),
socio-economic
factors
Modied PW 79 Various
+self-generated
Cardinal
Cluster analysis
(average linkage
+ ward) (see study
from 1993)
canonical correlation
Own investigation
(1998)
Accounting
rules
Modied
Uniform
TRANSACC
Reference Matrix
Ordinal !
dichotomised
Cluster analysis
(average,
complete,
single linkage),
multidimensional
scaling
50
Various
because
hierarchical
15
Various
because
hierarchical
For 4-cluster
solution: European,
North-American,
JAP/SWE/ESP,
Australia
analysis
Find a hierarchical
classication based
on accounting rules
Classication criterion
341
Main eects
Dierences
Single linkage
Chaining
Complete linkage
Chaining
342
4. Multidimensional scaling
2m
xm
5
m 2m y A m x m
m
RT
5
2A m m
2m
xm
m
$ SS1
5
5
RT
A m y A x ym 2A m
SS1
yA
> 0!
1
z 1
yA m z
m z yA m z2
. . .2
information of the observed similarities or distances only so that the spatial structure can be
displayed relatively independent of the chosen
distance or similarity measure (Bacher, 1996, pp.
7476).
The SM coecients are used in the following as
an input of the MDS only because this classical
variant of the method is invariant against monotone transformations. Fig. 2 shows the result of
the 2-dimensional solution. The STRESS value
a quality measure for the adequacy of the conguration after Kruskal (1964, p. 3) amounts to
0.16672. So, the picture suciently depicts the
dissimilarities of the national accounting systems
under review. We note that the same groups as in
the cluster analysis can be identied. But the micro
structure within the groups does not correspond
with the SM solutions, e.g. Switzerland and UK
are very close. This contradiction seems to be
a particular outcome of the ordinal use of the
distance measures. Typically, the MDS clearly
depicts the macrostructure but not the microstructures (Gordon, 1993/1981, p. 137).
Although the results correspond with the cluster solutions one important question remains
343
344
9
Relation for Australia/North-America: 17:6; Australia/
Europe: 33:15.
345
346
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